[Federal Register Volume 76, Number 168 (Tuesday, August 30, 2011)]
[Rules and Regulations]
[Pages 53818-53819]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2011-22066]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9536]
RIN 1545-BK40


Determining the Amount of Taxes Paid for Purposes of the Foreign 
Tax Credit

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final and temporary regulations.

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SUMMARY: This document contains a correction to final and temporary 
regulations (TD 9536) that were

[[Page 53819]]

published in the Federal Register on Monday, July 18, 2011, providing 
guidance relating to the determination of the amount of taxes paid for 
purposes of the foreign tax credit. These regulations address certain 
highly structured arrangements that produce inappropriate foreign tax 
credit results. The regulations affect individuals and corporations 
that claim direct and indirect foreign tax credits.

DATES: This correction is effective August 30, 2011, and is applicable 
beginning July 18, 2011.

FOR FURTHER INFORMATION CONTACT: Jeffrey Cowan, (202) 622-3850 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION: 

Background

    The temporary and final regulation (TD 9536) that is the subject of 
this correction is under section 901 of the Internal Revenue Code.

Need for Correction

    As published July 18, 2011 (76 FR 42036), TD 9536 contains an error 
that may prove to be misleading and is in need of clarification.

Correction of Publication

    Accordingly, the publication of the final and temporary regulations 
(TD 9536), that were the subject of FR Doc. 2011-17916, is corrected as 
follows:
    On page 42037, column 2, in the preamble under the caption 
``Explanation of Provision'', first paragraph, tenth line from the 
bottom, the language, ``2(e)(5)(iv)(B)(1)(iii) that a foreign'' is 
corrected to read ``2T(e)(5)(iv)(B)(1)(iii) that a foreign''.

Treena V. Garrett,
Federal Register Liaison, Publications and Regulations Branch, Legal 
Processing Division, Associate Chief Counsel, (Procedure and 
Administration).
[FR Doc. 2011-22066 Filed 8-29-11; 8:45 am]
BILLING CODE 4830-01-P